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Combining 11.3 Personnel into one document/policy statement?


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#1 Plastic Ducky

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Posted 17 December 2018 - 02:27 PM

Hello,

This is a dumb question, but I will swallow my pride as I am in need.

 

In writing up our SQF (Food Safety) policy manual, can I combine the articles under "11.3 Personnel" into one document/Policy statement? It seams easier to talk about; Communicable  Disease Control, Hand Washing, Clothing, and Jewelry under one umbrella "Production GMP" statement.

 

I apologize if this is a wacky question. This is my first time building a previously non-existent policy manual. Any guidance from y'all is greatly appreciated. 

 

 

 



#2 FSQA

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Posted 17 December 2018 - 02:37 PM

Shouldn't be an issue IMO, as long as you are satisfying the requirement Under one program or multiple Policy/SOP's.

 

The auditors tend to look if there is a policy in existence, and if cGMP practices are followed as written in the policy.

 

Good luck.



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#3 Simon

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Posted 17 December 2018 - 03:28 PM

Yes I have seen lot's of these.  In the UK "Hygiene Code of Practice" and covers everything related to personal hygiene.  Much easier to communicate and train out also.  Good luck PD.

 

Regards.
Simon


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#4 Hoosiersmoker

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Posted 20 December 2018 - 12:51 PM

We covered this under one GMP SOP / policy and has never been cited as non-compliant or any question raised. Remember the point is that the elements are all included, trained, implemented and followed adequately and you can prove they are adequate for their purpose.



#5 sqflady

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Posted 21 December 2018 - 01:48 PM

As others have said, absolutely you can combine them.  We have combined 11.3 and 11.4 into what we refer to as our "GMP Policy".  



#6 Hoosiersmoker

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Posted 21 December 2018 - 02:01 PM

Another thing you can do is include the different articles into other SOPs / policies. For instance, our visitor policy assigns the responsibility for "screening" visitors to determine if they are sick. Our "GMP" SOP has a section that covers the company's responsibility  to protect our processes and products by making determinations whether or not an employee is sick. You can add them wherever you want and as long as the employees have been trained (and you can prove it) you're covered.






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